State Health and Value Strategies (SHVS) developed this resource page to serve as an accessible one-stop source of information for states in “unwinding” the Medicaid continuous coverage requirement. The Families First Coronavirus Response Act (FFCRA) Medicaid continuous coverage requirement allowed people to retain Medicaid coverage and get needed care during the pandemic. On December 29, 2022, President Biden signed into law the Consolidated Appropriations Act, 2023 (CAA), an omnibus funding package that decoupled the continuous coverage provision from the end of the COVID-19 public health emergency by providing a fixed end date of March 31, 2023. These resources are designed to support states during this major coverage event, including developing processes that prioritize coverage retention. SHVS will update this page frequently with new resources as they become available. For more information about how states are unwinding the continuous coverage requirement, SHVS is highlighting examples of the work states are engaging in to prepare for and operationalize unwinding in our series States of Unwinding.
State Health and Value Strategies (SHVS) developed this resource page to serve as an accessible one-stop source of information for states in “unwinding” the Medicaid continuous coverage requirement. The Families First Coronavirus Response Act (FFCRA) Medicaid continuous coverage requirement allowed people to retain Medicaid coverage and get needed care during the pandemic. On December 29, 2022, President Biden signed into law the Consolidated Appropriations Act, 2023 (CAA), an omnibus funding package that decoupled the continuous coverage provision from the end of the COVID-19 public health emergency by providing a fixed end date of March 31, 2023. These resources are designed to support states during this major coverage event, including developing processes that prioritize coverage retention. SHVS will update this page frequently with new resources as they become available. For more information about how states are unwinding the continuous coverage requirement, SHVS is highlighting examples of the work states are engaging in to prepare for and operationalize unwinding in our series States of Unwinding.
This page provides communications resources designed to support states as they prepare for the various stages of work needed to inform stakeholders and consumers about the upcoming end of the Medicaid continuous coverage requirement. The end of the Medicaid continuous coverage requirement presents states with tremendous opportunities to keep individuals enrolled in Medicaid or transition to another form of health coverage.
On Thursday, November 16, State Health and Value Strategies hosted a webinar on provisions included in the Consolidated Appropriations Act, 2023 (CAA) that require states to provide children up to age 19 with 12 months of continuous enrollment (CE) in Medicaid and the Children’s Health Insurance Program starting January 1, 2024. During the webinar, experts from Manatt Health reviewed recent sub-regulatory guidance from the Centers for Medicare & Medicaid Services and considerations for states as they prepare to newly take up CE for children or modify existing CE policies to meet the CAA requirement.
This expert perspective provides insights on the temporary section 1902(e)(14) waiver flexibilities that may be valuable for the Centers for Medicare & Medicaid Services to consider extending or authorizing permanently to streamline and improve post-unwinding renewal processes. An informal and anonymous survey conducted by State Health and Value Strategies (SHVS) asked states to rate the value of these flexibilities during unwinding and their level of interest in making flexibilities permanent. Findings are not representative of all states and should be interpreted with caution.
During the unwinding of the Medicaid continuous coverage requirement there has been a strong focus on monitoring the impacts of eligibility redeterminations. A review of public unwinding data identified nine states that are voluntarily reporting Medicaid reinstatement data—including reinstatements as a result of CMS guidance on conducting ex parte at the individual level, as a result of fair hearing cases, or re-enrollment into Medicaid and the Children’s Health Insurance Program within the 90-day reconsideration period. This expert perspective reviews current state reporting of reinstatement data and provides recommendations for the reporting of such data.
The Centers for Medicare & Medicaid Services released new data related to the unwinding of the federal Medicaid continuous coverage requirement, along with additional unwinding resources. This expert perspective reviews newly available Medicaid, Children’s Health Insurance Program (CHIP), and Marketplace data, and summarizes key findings pertaining to Medicaid and CHIP enrollment, applications, and renewals, as well as Marketplace transitions.
Many states are actively working to make changes to their systems to enable ex parte renewals at the individual level and implement mitigation strategies to ensure eligible Medicaid and CHIP enrollees retain coverage until those system changes are complete. This tool is intended to: (1) help states identify common policies and/or operational processes that, if adjusted, could improve ex parte rates and renewal functionality, and (2) facilitate internal, cross-divisional Medicaid agency discussions across policy, operational, and information technology systems.
The open enrollment period (OEP) for health insurance Marketplaces will run from November 2023 to January 2024. This OEP will take place while most states are also conducting Medicaid renewals during the unwinding of the Medicaid continuous coverage requirement. State Health and Value Strategies has created sample messages and accompanying social media graphics to support states during the simultaneous Medicaid unwinding and open enrollment period. States can use this content in their outreach efforts to communicate important Marketplace enrollment opportunities to consumers, including those that may transition from Medicaid coverage.
As many states are implementing mitigation strategies to ensure compliance with the federal requirement to conduct ex parte renewals at the individual level, SHVS created model Medicaid reinstatement notice language which is intended to provide states with models for communicating key information to enrollees regarding their reinstatement. States can tailor and modify the templates for their programs and specific mitigation plans. The expert perspective also includes tips for writing and disseminating effective notices, based on enrollee feedback.
This expert perspective summarizes CMS’ recently released State Health Official letter providing guidance on the requirement in the Consolidated Appropriations Act, 2023 (CAA) that all states must adopt 12-months of continuous enrollment (CE) for children effective January 1, 2024. Key topics addressed in the guidance include the specific eligibility groups subject to CE under the CAA, the limited exceptions under which CE may be discontinued prior to 12 months, the impact of CE on children in carceral settings, and implementation requirements for states.
On September 29, the Centers and Medicare & Medicaid (CMS) published a new release of state-reported Medicaid unwinding data through its Unwinding and Returning to Regular Operations after COVID-19 landing page. Like previous releases of data, CMS includes national and state-specific metrics pertaining to Medicaid and CHIP eligibility renewal outcomes and total enrollment in June (and preliminary data for July). This month, as part of its timeline of planned data releases, CMS newly shared more comprehensive data on Marketplace enrollment and transitions—including cumulative enrollment data between April and June for HealthCare.gov, State-Based Marketplaces, and the Basic Health Programs—and separate CHIP enrollment in April 2023.
As states are working diligently to operationalize the unwinding of the Medicaid continuous coverage requirement, State Health and Value Strategies has been tracking the creative strategies states are implementing to minimize coverage losses. This expert perspective highlights all the hard work states are engaged in and spotlights innovative strategies other states may want to consider adopting. SHVS will continue to track and share state efforts to support coverage through the unwinding period. If your state is implementing a new effort to reach enrollees, or if you have questions about how you can implement an example included in this EP, please be in touch.
Given the potential to reduce coverage losses during the unwinding, there is intense interest in data that monitors transitions between Medicaid and Marketplace coverage. State-Based Marketplaces (SBMs) that operate their own eligibility platform should consider releasing available data on Marketplace transition outcomes. This expert perspective highlights recommendations for SBMs, such as providing context and making the data easy to find. The expert perspective includes an interactive map with links to SBMs reporting Marketplace transition outcome data and a table of the indicators that states are reporting on. SHVS will continue to update this EP as more SBMs publish unwinding data.
The unwinding of the Medicaid continuous coverage requirement represents the largest nationwide coverage transition since the Affordable Care Act, with significant health equity implications. Given the intense focus on coverage transitions during the unwinding, some states are publishing their data to monitor progress. To date, 42 states (including the District of Columbia) have released unwinding data in either an interactive dashboard or static pdf format, or are making public their required CMS Monthly Unwinding Data reports. This expert perspective includes an interactive map with links to state dashboards and reports to CMS. SHVS will continue to update this EP as more states publish their unwinding data.
On August 30, 2023, the Centers for Medicare & Medicaid Services (CMS) issued a State Medicaid Director Letter (SMDL) instructing states to assess whether they are in compliance with federal Medicaid regulations that require all renewal processes be conducted at the individual level. This expert perspective summarizes the SMDL, which lays out immediate actions that states must take to determine if they are out of compliance with the federal renewal requirements and mitigate compliance issues.
On August 30, the Centers for Medicare & Medicaid Services (CMS) issued a State Medicaid Director Letter (SMDL) instructing states to assess whether they are in compliance with federal Medicaid regulations that require all renewal processes be conducted at the individual level. This expert perspective reviews the Federal Financial Participation match available to states as they work to come into compliance with the requirements of the SMDL.
This diagnostic assessment tool is designed to assist states in assessing whether they are conducting ex parte and other renewal processes at the individual level in accordance with federal regulatory requirements. To use this tool, states should convene a team of key policy, operations and systems owners to review and answer these questions. This will require close review and analysis of eligibility and enrollment policies, IT system business rules and other system artifacts, and operating procedures.
This expert perspective describes how states can use consumer surveys to better understand coverage transitions during the unwinding. The EP highlights survey recommendations, such as survey mode, target population and timing, communications best practices and agency coordination, and includes a list of sample survey questions for states to download.
Medicaid, CHIP, Marketplace and integrated human services call centers are experiencing a surge in the number of callers seeking information about their health coverage with the end of the Medicaid continuous coverage requirement. In some states, high call volume is translating into long wait times and high rates of call abandonment, adversely affecting Medicaid and CHIP enrollees who rely on the call center as a critical source of assistance and support. Recognizing the crucial role of call centers in supporting enrollees throughout the eligibility and enrollment process, states can use this toolkit to identify opportunities and explore strategies to improve call center functionality.
On July 28, 2023, the Centers for Medicare & Medicaid Services released publicly state-reported data providing a window into how the unwinding of the federal Medicaid continuous coverage requirement is progressing. This expert perspective summarizes the data release, provides a timeline for CMS’ continued release of unwinding data and highlights the importance of context and the imperative for stakeholders to tread carefully when making interpretations about the data.
The unwinding of the Medicaid continuous coverage requirement represents the largest nationwide coverage transition since the Affordable Care Act, with significant health equity implications. Given the intense focus on coverage transitions during the unwinding, some states are publishing their data to monitor progress. To date, 32 states and the District of Columbia have released unwinding data in either an interactive dashboard or static pdf format, or are making public their required CMS Monthly Unwinding Data reports. This expert perspective includes an interactive map with links to state dashboards and reports to CMS. SHVS will continue to update this EP as more states publish their unwinding data.
With the restarting of eligibility redeterminations, millions of Medicaid enrollees are now at risk of losing their coverage and there is intense interest in monitoring the impact on coverage. As unwinding data is becoming public, it is difficult to compare across states as they are staging redeterminations in different months and states are using different terminology, definitions, and population denominators on their reporting. This expert perspective highlights recommended best practices for states to follow such as the timely release of data, prioritizing key measures, publishing disaggregated data, and providing context and transparency.
The unwinding of the Medicaid continuous coverage requirement represents the largest nationwide coverage transition since the Affordable Care Act, with significant health equity implications. Given the intense focus on coverage transitions during the unwinding, some states are publishing their data to monitor progress. To date, 29 states and the District of Columbia have released unwinding data in either an interactive dashboard or static pdf format, or are making public their required CMS Monthly Unwinding Data reports. This expert perspective includes an interactive map with links to state dashboards and reports to CMS. SHVS will continue to update this EP as more states publish their unwinding data.
As states continue the unwinding of the Medicaid continuous coverage requirement and redetermining their enrollees, states across the country have reported scams asking consumers for financial or personal information are prevalent. This expert perspective provides recommendations on what state communications and digital teams can do to mitigate online scams and protect official sources of information.
As a result of the Medicaid renewal process, which resumed in April 2023, it is expected that millions of people across the country will lose Medicaid and in some cases, CHIP coverage. This presents State-Based Marketplaces (SBMs) with an opportunity to target outreach efforts to those audiences who have recently lost Medicaid or CHIP to help eligible individuals retain access to affordable healthcare through the Marketplace. This new expert perspective focuses on best practices for timing and strategy in consumer outreach to consumers that are no longer eligible for Medicaid to help states develop a consumer “chase campaign”.
To help states respond to the ongoing COVID-19 pandemic, the White House, the U.S. Department of Health and Human Services, and the Centers for Medicare and Medicaid Services have invoked their emergency powers to authorize temporary flexibilities in Medicaid and the Children’s Health Insurance Program. Congress’s legislative relief packages have provided additional federal support for state Medicaid programs, subject to certain conditions. The timeframes for these emergency measures are summarized in the chart, including the effective dates and expiration timelines dictated by law or agency guidance.
These animated videos may be used by states across social media and digital platforms to reach enrollees with important information about the continuous coverage unwinding. Key messages encourage consumers to update their contact information and look in the mail for updates about Medicaid renewals to avoid gaps in their coverage. Videos are created in 15, 30, and 60-second lengths and are available in English and Spanish. States may customize the end card of each video by contacting Laura Buddenbaum at lbuddenbaum@princeton.edu to connect with our communications TA partners providing customizations.
These infographics provide an overview of the key changes to the parameters for unwinding enacted by the CAA as well as an illustrative continuous coverage unwinding timeline under the CAA. The infographics are intended to help states communicate internally or with key stakeholders about the Medicaid continuous enrollment condition provisions in the CAA and can be downloaded to use in communications.
Google recently announced it is highlighting Medicaid renewal-related information in relevant search results to make the information easier for consumers to find. This expert perspective provides more information on the new search features and how state health agencies can ensure their landing pages appear in Google search results related to Medicaid renewal.
The Tracking Medicaid Enrollment Growth During the COVID-19 Pandemic Databook provides a comprehensive, detailed look at Medicaid enrollment trends to-date. Using Medicaid enrollment data from over 40 states, the Databook provides a comprehensive, detailed look at Medicaid enrollment trends from the beginning of the COVID-19 pandemic through December 2022. The Databook provides enrollment detail by state across four eligibility categories: expansion adults, children (including those enrolled in CHIP), non-expansion adults, and aged, blind, and disabled individuals. It also compares enrollment trends across expansion and non-expansion states. While variations in states reporting mean that the enrollment numbers in this report are not necessarily comparable across states (and should not be summed across states), the data reported do allow states and others to track enrollment trends. As a companion to the Databook, Manatt Health authored an issue brief, The State of Medicaid Enrollment Approaching Continuous Coverage Unwinding, that summarizes key findings from an analysis of the Databook.
To maximize efforts to maintain coverage, state Medicaid agencies and Marketplaces can now leverage digital channels as part of their overall outreach and communications efforts. Rapidly evolving changes in consumer media consumption habits as well as shifts in digital channels, and the ability to leverage data sources, enables granular audience targeting and efficient use of resources. These can be incorporated into an overall integrated outreach and education campaign to maximize renewals and coverage retention.
The tool aims to help states qualify for the sustained enhanced Federal Medical Assistance Percentage, avoid corrective action imposed by CMS, promote continuity of coverage and care during unwinding, and make long-term improvements to eligibility and enrollment infrastructure.
The long-expected return to Medicaid eligibility re-determinations and renewals, referred to as the “Medicaid unwinding,” has begun. This expert perspective provides a checklist of actions state-based marketplaces and state insurance departments can take, if they haven’t already, to reduce gaps in coverage and minimize disruptions in care. Many are designed to be temporary, and will be critical to helping people navigate an unprecedented period of disruption. Other actions involve policies or operational improvements that could reap long-term benefits by mitigating risks inherent in Medicaid-Marketplace “churn.”
Now that the details and timing associated with the unwinding of the Medicaid continuous enrollment requirement have been established by the Consolidated Appropriations Act, 2023 (CAA), states can start refining and implementing long laid plans to restart eligibility redeterminations and return to routine eligibility and enrollment operations. This expert perspective outlines the relevant reporting requirements that were included in the CAA and the corresponding reporting guidance provided by CMS in its January 2023 State Health Official letter, and presents considerations for state officials as they fulfill their federal obligations and address calls from advocates and others for transparency.
This expert perspective summarizes a recent federal court ruling that impacted CMS’ enforcement of an interim final rule (IFR) that narrowed CMS’ interpretation of the Medicaid continuous coverage requirement in the Families First Coronavirus Response Act (FFCRA).
On Wednesday, February 8, State Health and Value Strategies hosted a webinar during which experts from Manatt Health reviewed CMS’ recently released State Health Official (SHO) letter related to “unwinding” the Medicaid continuous coverage guarantee, based on provisions included in section 5131 of the Consolidated Appropriations Act, 2023 (CAA).The webinar reviewed the additional detail and operational expectations of states during the unwinding of Medicaid continuous coverage as laid out in the SHO letter, and discussed key considerations for state policymakers. As a reminder, SHVS has created a single-stop resource page to support states as they plan for unwinding.
On January 27, 2023, the Centers for Medicare & Medicaid Services (CMS) released a State Health Official (SHO) letter, “Medicaid Continuous Enrollment Condition Changes, Conditions for Receiving the FFCRA Temporary FMAP Increase, Reporting Requirements, and Enforcement Provisions in the Consolidated Appropriations Act, 2023.” This SHO letter is the second in a series of guidance related to section 5131 of the Consolidated Appropriations Act, 2023 (CAA), which established a fixed end date for the Medicaid continuous coverage requirement, a gradual phase-down for the enhanced federal match, and new guardrails for mitigating coverage loss for individuals who continue to be eligible.
On January 23, 2023, the Federal Communications Commission issued an important ruling that provides states with new flexibility to support enrollee outreach and communication efforts as part of their processes to unwind the Medicaid continuous coverage requirement. The ruling permits state agencies and their partners to send text messages and make phone calls to individuals about enrollment-related issues not only for Medicaid but for other state-run health insurance programs, including marketplace coverage. This expert perspective reviews the ruling and implications for states.
While much attention has been paid to how states can approach the unwinding of the continuous coverage requirement to prioritize the retention of Medicaid coverage and transitions to marketplace coverage, less attention has been paid to the role of employer-sponsored insurance. To get a sense for the size of the group that might have employer-sponsored coverage as an option, this issue brief discusses the proportion of individuals with an offer of employer-sponsored coverage by income and state, and the proportion of those offers that are considered affordable based on premium cost.
Many consumers will find the relationship between Medicaid, the marketplace, and employer-sponsored insurance to be more complicated than ever in 2023 as the unwinding of the continuous coverage requirement begins. Much of the focus of Medicaid unwinding planning in states and the federal government has been on helping eligible people keep Medicaid coverage and steering the millions of people losing Medicaid eligibility toward the health insurance marketplace. Less attention has been devoted to the millions of people who are expected to be eligible for employer-sponsored insurance when their Medicaid coverage ends. This issue brief discusses how state Medicaid agencies, state-based marketplaces, labor departments, and employers can play critical roles in helping people understand and navigate their coverage options.
On Wednesday, January 11 State Health and Value Strategies hosted a webinar on the Consolidated Appropriations Act, 2023, an omnibus funding package that includes government appropriations through September 30, 2023 as well as a number of health policy provisions. Included in the package is a date certain for the expiration of the Medicaid continuous coverage requirement, a gradual phase down of the Families First Coronavirus Response Act enhanced federal match rate, and new guardrails to protect against inappropriate coverage loss and smooth coverage transitions.
When the federal Medicaid continuous coverage requirement expires, states will be required to redetermine eligibility for over 90 million Medicaid enrollees, threatening the historic coverage gains achieved during the federal public health emergency (PHE). One of the most effective tools for states to mitigate coverage loss for eligible people during “unwinding” and beyond is ex parte redetermination. This Q&A is intended to serve as a resource for states looking to improve their current ex parte processes to support their efforts during unwinding and well beyond.
After weeks of negotiations during the lame duck session, Congress passed the Consolidated Appropriations Act, 2023, an omnibus funding package that includes government appropriations through September 30, 2023 as well as a number of health policy provisions. Among the health policies included in the package, section 5131 of the legislation provides a fixed end date for the Medicaid continuous coverage guarantee (March 31, 2023), a gradual phase down of the Families First Coronavirus Response Act (FFCRA) enhanced federal match rate, and new conditions, reporting requirements, and enforcement mechanisms to prioritize coverage retention and smooth coverage transitions during the “unwinding.” This expert perspective provides an overview of these unwinding provisions and considerations for states.
To avoid potential coverage losses when the federal public health emergency (PHE) is declared over and the Medicaid continuous coverage requirement ends, states will need to communicate with enrollees and other stakeholders, including community partners, about the actions they need to take to keep individuals enrolled in Medicaid or transition to another form of health coverage. This expert perspective reviews examples of states that are collaborating with community partners to support their outreach and engagement efforts.
State Health and Value Strategies is hosting a webinar Unwinding of the Public Health Emergency: What’s Next for States on Wednesday, November 2. The webinar will feature a discussion of the key considerations and requirements for state Medicaid/CHIP agencies at the end of the PHE, including making permanent or terminating temporary COVID-19 flexibilities and returning to normal eligibility and enrollment processes. Presenters will highlight the intersection with our dynamic policy environment, including the recent CMS Proposed Rule on Medicaid and CHIP Eligibility, Enrollment, and Renewal.
This expert perspective provides an overview of the eligibility and enrollment proposed rule released by CMS on August 31 and details how the proposed rule seeks to strengthen existing eligibility, enrollment, and renewal operational processes in an effort to close gaps in coverage and extend best practices identified by CMS and states in the course of preparing for unwinding the federal public health emergency (PHE). Comments on the proposed rule are due no later than November 7, 2022.
The impending end of the federal public health emergency (PHE) will be one of the most significant health coverage events since the implementation of the Affordable Care Act, as state Medicaid agencies across the country will resume regular renewal processes for over 89 million people. The resumption of redeterminations means that many Medicaid enrollees will need to affirmatively renew their coverage and those who are no longer eligible for Medicaid will need to transition to other forms of coverage or go uninsured. To help states effectively communicate with enrollees, this expert perspective provides research-based recommendations regarding terminology that can be used in consumer education and outreach.
For more than two years, states have maintained coverage of their Medicaid enrollees as a condition of receiving enhanced federal Medicaid funding under the Families First Coronavirus Response Act, resulting in considerable increases in coverage for all Americans, including pregnant and postpartum individuals. When the federal Medicaid continuous coverage requirement expires, states will redetermine eligibility for nearly all Medicaid enrollees, including roughly 1.7 million people enrolled in a Medicaid or CHIP pregnancy eligibility group. This issue brief reviews proactive strategies that states can deploy to support postpartum individuals in maintaining health coverage and access to care when the Medicaid continuous coverage guarantee ends and beyond.
At the end of the federal public health emergency, states will need to redetermine eligibility for nearly all Medicaid enrollees in the largest healthcare event since the Affordable Care Act. In order to avoid potential coverage losses, states will need to communicate with enrollees and other stakeholders about the actions they need to take to keep individuals enrolled in Medicaid or transition to another form of health coverage. One way that states are promoting transparency in their communications and planning efforts is through the public release of their unwinding operational plans. This expert perspective highlights several states that have made their unwinding operational plans publicly available as well as examples of states’ ongoing communication efforts, including outreach campaigns to Medicaid enrollees, strategies for collaborating with stakeholders, and collaborative initiatives within Marketplace states.
The unwinding related section 1902(e)(14) strategies newly available to Medicaid and CHIP agencies can provide significant relief to states facing pending eligibility and enrollment actions and processing delays, workforce and systems limitations, and other operational challenges. Ensuring eligible individuals do not lose coverage for procedural or administrative reasons and supporting those who are ineligible for Medicaid/CHIP transition to Marketplace coverage will be paramount for all states as they begin to resume normal operations when the federal public health emergency (PHE) ends. This expert perspective outlines the time-limited targeted enrollment flexibilities that CMS has availed to states through section 1902(e)(14) waiver authority and discusses considerations beyond the strategies described in federal guidance and supplemental resources. This expert perspective has been updated as of August 5, 2022 to include reference to additional guidance released by the Centers for Medicare & Medicaid Services.
This expert perspective focuses on strengthening communications to enrollees once the federal public health emergency is lifted and the continuous enrollment requirement ends to ensure that those who are eligible maintain their coverage, and those who are ineligible are transitioned to a Marketplace plan or other insurance. The intention is to help states develop a timeline within their communications plans to coordinate and sequence outreach to these consumer groups. Critical in this effort to reduce churn will be effective coordination with stakeholders. This expert perspective outlines outreach strategies and tactics state Medicaid agencies and State-Based Marketplaces can implement to effectively inform enrollees what is happening and what actions they may need to take to stay insured.
This expert perspective, the second in a series about maintaining continuity of coverage and care during the public health emergency unwinding, identifies strategies for state-based Marketplaces (SBMs), in partnership with Medicaid agencies, departments of insurance, consumer assisters, and participating insurers, to help maintain continuity of care. The first expert perspective noted strategies that state Medicaid agencies can use to mitigate disruptions to coverage and care. A third expert perspective will discuss strategies for the SBMs and their partners to help ensure continuity of coverage.
The unwinding related section 1902(e)(14) strategies newly available to Medicaid and CHIP agencies can provide significant relief to states facing pending eligibility and enrollment actions and processing delays, workforce and systems limitations, and other operational challenges. Ensuring eligible individuals do not lose coverage for procedural or administrative reasons and supporting those who are ineligible for Medicaid/CHIP transition to Marketplace coverage will be paramount for all states as they begin to resume normal operations when the federal public health emergency (PHE) ends. This expert perspective outlines the time-limited targeted enrollment flexibilities that CMS has availed to states through section 1902(e)(14) waiver authority and discusses considerations beyond the strategies described in federal guidance and supplemental resources. This expert perspective has been updated as of August 5, 2022 to include reference to additional guidance released by the Centers for Medicare & Medicaid Services.
Providing a retroactive coverage option in the Marketplace is one innovative strategy for eliminating coverage gaps between Medicaid and Marketplace coverage for people eligible to make that transition at the end of the public health emergency. Pennsylvania’s state-based Marketplace, Pennie, is considering an optional retroactive coverage policy. This expert perspective describes the retroactive coverage policy innovation and its benefits, and offers strategies for states to consider in their implementation that will maximize coverage continuity, minimize adverse selection, and address potential operational challenges.
Improving ex parte rates as part of the Medicaid renewal process is one of the most effective tools available to states to mitigate coverage loss for eligible individuals when the public health emergency (PHE) ends. There are tremendous benefits to enrollees and to states in maximizing eligibility redetermination through an ex parte process. As states develop their unwinding policies and operational plans in readiness for the end of the PHE, improving ex parte rates should be at the top of their priority list. This toolkit contains a table that can be used by a state to examine current ex parte processes and identify and deploy additional strategies that could increase their ex parte rates.
This expert perspective, the first in a two-part series, outlines strategies state Medicaid agencies can take to identify people with high health needs and provide them with additional support to retain or transition their health coverage in order to maintain access to essential healthcare services when the current Medicaid continuous coverage requirement ends. A second expert perspective will identify complementary strategies state-based marketplaces and departments of insurance can implement to help these individuals transition without gaps in coverage or care.
On May 3, 2022, the Federal Communications Commission (FCC) opened a public comment period for feedback on a letter submitted by the Department of Health and Human Services Secretary Xavier Becerra and Centers for Medicare & Medicaid Services Administrator Chiquita Brooks-LaSure. The letter requests the FCC’s opinion on the use of text messages and automated calls to enrollees as states resume regular operations at the end of the COVID-19 Public Health Emergency. This expert perspective provides model comments to inform and support state responses to the FCC’s public comment period.
This toolkit highlights opportunities for states to leverage managed care plans to support unwinding the Medicaid continuous coverage requirement. Close collaboration between states and managed care plans will be essential to ensuring eligible individuals retain coverage in Medicaid/CHIP and easing transitions to the Marketplace. The toolkit, updated as of April 26, 2022, features guidance released by CMS for states on working with managed care plans.
This toolkit provides a communications planning guide designed to support state Medicaid agencies as they prepare for the upcoming end of the continuous coverage requirement. It outlines phases of planning to organize state efforts.
New state reporting templates and guidance released by the Centers for Medicare & Medicaid Services (CMS) on March 22, 2022, build upon a State Health Official letter released on March 3. The resources specify both the data and the metrics that states will be required to submit to monitor enrollment and renewal efforts as they resume routine Medicaid and CHIP operations following the end of the COVID-19 PHE. This expert perspective summarizes the new reporting requirements and presents a set of considerations for states as they begin implementing new unwinding policies, procedures, and reporting.
Once the public health emergency ends, state Medicaid agencies will need to recommence Medicaid eligibility redeterminations and renewals. As a result, up to 16 million people are projected to lose their Medicaid coverage, and an estimated one-third of these individuals will be eligible for subsidized coverage in the Affordable Care Act (ACA) Marketplaces. Whether a state’s Medicaid agency moves swiftly or slowly to process eligibility redeterminations, the commercial insurance market–and particularly the ACA Marketplaces–could experience a significant growth in enrollment. This issue brief identifies several areas in which state departments of insurance (DOIs) may want to coordinate with other agencies or external stakeholders, issue new regulations or guidance, and establish means for minimizing gaps in coverage or access to services.
On March 3, the Centers for Medicare & Medicaid Services (CMS) released a State Health Official (SHO) letter, “Promoting Continuity of Coverage and Distributing Eligibility and Enrollment Workload in Medicaid, the Children’s Health Insurance Program (CHIP), and Basic Health Program (BHP) Upon Conclusion of the COVID-19 Public Health Emergency.” This expert perspective summarizes the highly anticipated guidance, which clarifies CMS expectations for state Medicaid and CHIP agencies as they prepare to process outstanding eligibility and enrollment actions when the federal Medicaid continuous coverage requirement ends.
Medicaid agencies are required to send written notices to enrollees as they begin their redetermination process after the continuous coverage requirement ends. This document contains template notices designed for use by state Medicaid agencies in their efforts to communicate with enrollees. State Medicaid agencies can customize these documents by editing them to input their state seal or agency logo and other state-specific information. These notices incorporate recommendations from the Centers for Medicare & Medicaid Services and reflect insights from qualitative testing with Medicaid enrollees during focus groups in February 2022.
When the Families First Coronavirus Response Act Medicaid “continuous coverage” requirement is discontinued states will restart eligibility redeterminations, and millions of Medicaid enrollees will be at risk of losing their coverage. A lack of publicly available data on Medicaid enrollment, renewal, and disenrollment makes it difficult to understand exactly who is losing Medicaid coverage and for what reasons. Publishing timely data in an easy-to-digest, visually appealing way would help improve the transparency, accountability, and equity of the Medicaid program. This expert perspective lays out a set of priority measures that states can incorporate over time into a data dashboard to track Medicaid enrollment following the end of the continuous coverage requirement. For a detailed discussion of the current status of Medicaid enrollment and retention data collection and best practices when developing a data dashboard to display this type of information, SHVS has published a companion issue brief.
As state Medicaid and Children’s Health Insurance Program (CHIP) agencies develop their strategies for unwinding the federal Medicaid continuous coverage requirement under the Families First Coronavirus Response Act, many are looking to text messaging as a mechanism for outreach to their Medicaid and CHIP enrollees and communicating important information. This expert perspective describes states’ authority to send text messages and requirements for obtaining consent. The expert perspective also contains sample consent language to include in the Medicaid/CHIP application as well as template text messages.
The Families First Coronavirus Response Act (FFCRA) Medicaid “continuous coverage” requirement has allowed people to retain Medicaid coverage and get needed care during the COVID-19 pandemic. When continuous enrollment is discontinued, states will restart eligibility redeterminations, and millions of Medicaid enrollees will be at risk of losing their coverage. The current lack of publicly available and timely Medicaid enrollment, renewal, and disenrollment data will make it difficult to understand exactly who is losing coverage and for what reasons. One effective way to monitor this type of information is through the use of Medicaid enrollment and retention dashboards. This issue brief examines the current status of data collection to assess Medicaid enrollment and retention, summarizes potential forthcoming reporting requirements, and describes some of the best practices states should consider when developing a data dashboard to display this type of information. The issue brief lays out a phased set of priority measures and provides a model enrollment and retention dashboard template.
On Wednesday, November 10 State Health and Value Strategies hosted a webinar that provided an overview of strategies for states seeking to ensure that eligible enrollees are able to keep or transition to new affordable health coverage when the Medicaid continuous coverage requirement ends. States will be resuming eligibility and enrollment activities for all enrollees in Medicaid and the Children’s Health Insurance Program (CHIP), and as part of their planning, states have an opportunity to retain coverage gains experienced over the pandemic period by taking steps to ensure that eligible enrollees are able to keep Medicaid/CHIP coverage, and those who are eligible for subsidized Marketplace coverage are transitioned and enrolled. Experts from Manatt Health and McKinsey & Company discussed how states can prepare now by deploying strategies to update enrollee contact information, and make other eligibility and enrollment technology changes to better serve their residents.
Following the expiration of the Public Health Emergency (PHE), states will resume normal eligibility and enrollment activities for all enrollees in Medicaid and the Children’s Health Insurance Program (CHIP). The volume of expected redetermination activity at the end of the PHE is unprecedented. This issue brief reviews state Medicaid/CHIP agency data and information technology (IT) system “table stakes”—strategies that will have the highest impact for states seeking to ensure that eligible enrollees are able to keep or transition to new affordable health coverage when the PHE continuous coverage requirements end. If adopted, these strategies will also enable states to dramatically improve Medicaid/CHIP enrollment and coverage retention in the longer-term for people eligible for government subsidized health coverage.
At the end of the public health emergency (PHE), people currently enrolled in Medicaid and the Children’s Health Insurance Program are at risk of losing their coverage unless state Medicaid/CHIP agencies take steps to update enrollee mailing addresses and other contact information. This expert perspective examines the information technology system, policy, and operational strategies states can consider to update key enrollee contact information to ensure eligible enrollees are able to keep or transition to new affordable health coverage at the end of the PHE.
On Wednesday, April 29 State Health and Value Strategies hosted a webinar, State Strategies to Support Medicaid/CHIP Eligibility and Enrollment in Response to COVID-19. Many states are experiencing an increase in the volume of Medicaid applications due to the COVID-19 pandemic and the resulting economic crisis. It is important for states to understand the policy and operational strategies they can use to ensure that people who are eligible for the Medicaid program can apply, enroll and start receiving benefits as quickly as possible. During the webinar experts from Manatt Health reviewed strategies states can use to manage and process an increased number of Medicaid applications, and the federal authorities that permit states to do so. Communications experts from GMMB reviewed strategies for messaging to new and existing enrollees. As a companion to this webinar, SHVS has also published a Medicaid COVID-19 Messaging toolkit.
As a condition of receiving enhanced federal funding under the Families First Coronavirus Response Act (FFCRA), states are prohibited from terminating individuals enrolled in Medicaid as of March 18, 2020, or determined eligible on or after that date. These continuous coverage requirements run through the end of the month of the public health emergency (PHE), which was recently extended to October 22, 2020. Absent a further extension of the PHE, states have three months to implement a plan for unwinding the FCCRA continuous coverage requirements which are otherwise set to terminate on October 31, 2020. States will also need to identify which newly obtained eligibility and enrollment flexibilities they would like to make permanent beyond the termination of the PHE–especially in the context of emerging information that suggests that the duration of COVID-19 pandemic may extend well into 2021.
On Thursday, January 21 State Health and Value Strategies hosted a webinar on the long-awaited guidance to state Medicaid and CHIP agencies on resuming normal operations following the end of the COVID-19 public health emergency. During the webinar experts from Manatt Health discussed the sub-regulatory guidance and the implications for states, in light of the recent public health emergency renewal by Secretary Azar. The webinar reviewed the expectations laid out in the guidance related to timelines, consumer communications, and fair hearing processes for redetermining Medicaid eligibility for those who have had their coverage continuously maintained as a condition of receiving the temporary 6.2 percent FMAP increase under the Families First Coronavirus Response Act. Additionally, presenters discussed the expected processes and timelines for terminating, or making permanent where allowable, temporary federal flexibilities that were obtained.
Medicaid enrollment has increased by over 10 million (or 15 percent) from February 2020 through February 2021 across all states since the outbreak of the COVID-19 pandemic. States have a clear imperative to center health equity as they plan for the end of the public health emergency (PHE) given that Black, Latino/a, and other people of color are most at risk of coverage loss. This expert perspective highlights strategies states can implement to ensure that the end of the PHE does not exacerbate already widespread racial and ethnic disparities in our health care system.
On December 22, 2020, the Centers for Medicare and Medicaid Services released long-awaited guidance to state Medicaid and CHIP agencies on resuming normal operations following the end of the COVID-19 public health emergency. This issue brief provides a high-level summary of the CMS guidance related to: (1) conducting redeterminations for Medicaid enrollees who were continuously enrolled; (2) terminating, or extending where appropriate, temporary flexibilities; and (3) developing a consumer and provider communication strategy.